### May

21,2015 U. S. Department

of Transportation Docket Management

System 1200 New Jersey

Ave.,SE Washington,

DC 20590

Re: Summary

Processing:

ExemptionRequest

for marX The Spot Films Inc., Under Section 333 of the FAA ReformAct and Part 11of the Federal Aviation Regulations From;14C.F.R.

$$61.113(a)

and (b); 91.119(c);

91.121;91.151(a);

91.405(a); 9 1 .a07 @)(1); e 1 .409 (a)(2); 9 1 .ar7@)and (b).

Dear Sir or Madam:

Pursuant

to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act) and l4 C.F.R.

Part 11, marX The SpotFilms Inc., Inc. ("marX The Spot Films Inc.") operator of Unmanned

Aircraft Systems

("UASs") equipped

to conduct

commercial

flights for aerialphotography,

motion picturefilming, & videography (hereinafter

"the Purpose"),

hereby applies for an exemption

from the listed Federal Aviation Regulations

("FARs") to allow commercial

operation

of its UASs, so long as such operations

are conducted

subject to, and in accordance

with the conditions

outlined herein,

or as may be established by the FAA in an exemption

granted under either Section 333 or 49 U.S.C.

$ 44701(0.

marX The Spot

Films Inc. will accept

the conditions

setforth in Exemptions Nos. 11062

and its progeny

Nos. 11063 through 11067,11080,

11150, 11158, 11160, lli6l,and 11172("the SimilarExemptions).marX The Spot Films Inc., respectfully requests summary

approval

of this exemption

request.

marx The Spot Films Inc. seeks to operate

the following UAVs it currently posses under the exemption.

- DJI 51000

Octocopter

- SN - W13DCC05020145

- DJI Inspire Quadcopter I SN - 02V0024420

- Freefly

systemsALTA-

8 Motor,QuadArm - SN - MTSFFFSA20l5

- Freefly

systems Cinestar 8HL - SN-MTSFCS82014



### Date: 51211201 Page 1 of 12 Revision: Original

### As with theapproval of the Similar

Exemptions,

approval of this exemption

would thereby enhance public safety

and fulfill the Secretary of Transportation's

(the FAA Administrator's)

responsibilities

to "...establish

requirements

for the safe

operation

of such aircraft systems

in the national

airspace system."

Section 333(c)of the ReformAct. Id. $ 333(c) The nameand address

of the applicant

is:

marX The Spot

Films Inc. JustinMarx 1411 Jackson Street Hollywood

FL 33020 Ph.: 305-607-0235 Regulations

from which the exemption is requested: 14 C.F.R. $ 61.113(a)

and (b) 14C.F.R.

$ 91.11914

C.F.R. $ 91.121 14C.F.R.

$ e1.151(a) 14C.F.R.

$ 91.40s(a) 14C.F.R.

$ 407(aXl) l4 C.F.R.

$ a0e(a)(2) l4 C.F.R.

$ a17(a) and (b)

This exemption

application

is expressly

submitted

to fulfill Congress'

goal in passing

Section 333(a) through (c) of the Reform Act. This law directs

the Secretary

of Transportation

to considerwhether certain unmanned aircraft systems

may operatesafely in the national airspace system (NAS) before

completion

of the rulemaking

required under Section

332 of the Reform Act. In making this determination, the Secretary

is required

to determine

which typesof UASs do not create

ahazard to users of the NAS or the public or pose a threat to national

security in light of the following:

. The UAS's size,

weight, speed,

and operational

capability;

. Operation

of the UAS in closeproximity to airports and populated

areas; and

. Operation

of the UAS within visual line of sight of the operator.

ReformAct $ 333(a).

Lastly, if the Secretary determines

that such

vehicles "may operate

safely in the national

airspace system, the Secretary

shall establish

requiremenrs

for the safe

operation of such aircraft in the national

airspace system."

Id. $ 333(c)



### Date: 5/2112015 Page 2 ot 12 Revision: OriginalThe Federal Aviation Act, in addition to the authoritygranted by Section

333 of Reform Act. expressly

grants the FAA the authority

to issue exemptions.

This statutory

authorityby its terms includes

exempting

civil aircraft,

asthe term is definedunder$ 401 01 of the Act, that includes UASs, from the requirement hat all civil aircraft must havea current airworthiness certificate.

The Administrator

may grant an exemption from a requirement

of a regulation

prescribed undersubsection

(a) or (b) of this section or any sections

44702-44716

of the Transportation

Act if the Administrator

finds the exemption

in the public interest.

49 U.S.C. $ 44701(0. See also 49 U.S.C. S8 4471r(a),

44704; 14 C.F.R. $ 9l.203(aX1). marX The Spot Films Inc. is a film production company

that incorporates

the useof aerialcinematography

andvideography

into the television

and film industry,

andthe corporate sector. marX The Spot Films Inc. UASs are rotorcraft, weighting 55 pounds

or lessincluding payload. They operate,

undernormal conditions at a speed

not exceeding

50 knots and havethe capability to hover,

and move in the vertical and horizontal planes. They will operate

at altitudes

not exceeding

400 feet, as further specified, and only in line of sight. They will operate

only within the sterile

areas as described

in the marX The Spot Films lnc. Flight Operations

Manual.

ln support

of this application,

marX The Spot Films Inc. is submitting, the following manuals (hereinafter

"the manuals")

. Futaba 14SG 14 Channel Transmitter

Operating

manual(document

attached)

. Graupner

MZ-24 12 Channel

Transmitter

Operating

manual(document

attached)

. marX The Spot Films Inc. Motion PictureandTelevision Operations

manual (document

attached)

. DJI INSPIRE 1 UAS Aircraft Operating Manual, Exhibit 4 (document attached) ' DJI Si000 UAS Operating Manual, Exhibit 5 (document attached) ' DJI .A2 Flight Control system (document

attached)
Operations

in compliance

with these

manuals will insure

that the UAS will "not create ahazard to users of the national

airspace system, the public, the PIC, andthe film production crew" and that the aircraftwill operate in compliance

with the conditions

setforth in this application.



### Date:512112015 Page 3 ol 12 Revision: Original

### Given

thesmall size of the UASsinvolved

and the restricted

environment

withinwhich

they will operate, the applicant

falls squarely

within that zone

of safety

(an equivalent

level of safety)

in which Congress

envisioned

that the FAA must,by exemption, allow commercial

operations

of UASs to commence

immediately.

Also due to the sizeof the UASs, the restricted areas in which the relevant

UASs will operate

and the fact that aircraft will be flown by pilots holding at least a FAA privatepilot license, approval

of the application

presents no national

security issue. Given the cleardirectionin Section 333 of the ReformAct, the authoritycontained in the Federal Aviation Act, as amended; the strong

equivalent

level of safety

surrounding

the proposed operations,

and the significant

public benefit,including enhanced safety, reduction

in environmental

impacts, including reduced

emissions

associated

with allowing batterypowered UASs for these

functions instead

of turbine or gas power aircraftlrotorcraft and operations with pilots having at least

a private pilot license,

the grant of the requested exemptions

is in the public interest. Accordingly,

the applicant

respectfully

requests that the FAA grantthe requested exemption

without delay. AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY The applicant

proposes

that the exemption

requested

hereinapply to civil aircraft that have

the characteristics

andthat operate

with the limitations listed herein. These limitations

provide for an equivalent or higher level of safety to operations under the current regulatory structure because the proposed

operations

represent

a safety enhancement

to the currently "deemed safe" movie and televisionfilmingoperations that are conducted

v,ith conventional

aircraft.

marX The Spot Films Inc. notes that it has requested

that a Certificate

of Authorrzatron

(COA) not be required

for flight at or below 400 feet AGL, in Class

G airspace

and outside

of 5 nautical miles from the geographic center of an airportwherea letterof agreement hasnot been

entered into with the airport management. The limitationsand conditions to which marX The Spot Films Inc. agrees to be boundwhen conducting

commercial

operations

underan FAA issued

exemption

are as follows:
1. The UAS must weigh less than 55 pounds,

including energy

source(s)

and equipment. Operations

will be limited to the aircraft described in the proprietary

manuals:
2. The UA may not be flown at a groundspeed in excess

of 50 knots. 3. Flights must be operated at an altitude

of no more than 400 feet above ground level (AGL) as indicated

by the procedures

specified

in the "operators'

manuals".

All altitudes

reported to AfC must be in feetAGL. 4. The UA must be operated within visual line of sight (VLOS) of the PIC at all times. This requires the PIC to be ableto use human vision unaided

by any device

otherthan corrective lenses, as specified

on the PIC's FAA-issued medical certificate.



### Date: 512112015 Page 4ol 12 Revision: Original

### 5.All operations must utilize a visual observer (VO).The

VO maybe used

to satisfy the VLOS requirement,

as lor,g asthe PIC always

maintains

VLOS capability.

The VO andpIC mustbe ableto communicate

verbally at all times. 6. Prior to each

flight the PIC will inspect the UAS to ensure

that it is airworthy,

and in condition for a safe

flight' If the inspection reveals a conditionthat aflects the safe op.ruiion of the UAS, the aircraft

will not be operated

until the necessary

maintenance

or repair hasbeen

performed and the UAS is found to be airworthy and in conditionfor safe flight. The GroundControl Station'if utilized,will be includedin the preflight inspection. All maintenance,

modifications. and repairs

will be properly documented in the aircraft records.

7. Any UAS that has undergone maintenance

or modifications

that affectthe operation or flight characteristics

of the UAS, e.g. replacement of a flight critical component, must undergo

a functional

testflight in accordance with the "manual". The PIC who conducts the functional

test flight must document

it with an entry in the UAS aircraft records of the flight. The requirements and procedures

for a functional

testflight and a protocolfbr aircraft record entry must be added to the "manuals". 8' The operator

will follow the manufacturer's UAS aircraftand component maintenance, overhaul,

replacement,

inspection,

and life limit requirements. 9' The PIC will possess at minimum. a private pilot certificate and a State

Issued Drivers License. The PIC will also

meet the flight reviewrequirements specified

in l4 C.F.R.

g 61.56 in an aircraft in which the PIC is ratedon his or her pilot certificate. 10. Prior to operations

conducted

for the Purpose,

the PIC will haveaccumulated and logged,in a manner

consistent

with l4 C.F.R.

$ 61.51(b),

25 hours

of totaltime asa UAS rotorcraft pilot andat least

ten hours

logged asa UAS pilot with a similarUAS type (single blade or multirotor). Prior documented flight experience

that was obtained

in compliance

with applicable regulations

will be used

to satisfl'

this requirement.

Training.proficiency,

and experience building flights may alsobe conducted under this exemption

to accomplish

the required

flight cycles and flight time. During training, proficiency, and experience

building flights, all persons not essential

for flight operations

will be considered

non-participants,

and the pIC will operate the sUAS with appropriate distance from non-participants

in accordance

with l4 C.F.R.

S 9l , I I 9. 1 l. Prior to operations

conducted

fbr the purpose

of motion picturefilming (or similar operations).

the PIC must have

accumulated

and logged,

in a manner

consistent

with l4 C.F.R.

S 61.51(b)'

a ninimum of five hours as UAS pilot. operating the make

and model

of UAS to be utilized for operations

under the exemption,

in addition

to three take-ofts

and landines

within the preceding

90 days.


### Date: 5121/2015 Page 5 oI 12 

### Revision: Original

### Under

thisexemption,

the PIC must

operate the UA anappropriate

distance away from nonparticipants

in accordance

with 14 C.F.R.

$ 91.119.,

during training, proficiency,

experience building, and take offand landingflights in orderto accomplish the required

flight time and to remaincurrent

within the prescribed

90 day period. "Nonparticipants" are defined

as all persons who are not essential

for flight operations. The UA will not be operated directly over any person, or below an altitude

that is hazardous

to persons or propefiy on the surface in the event

of a UAS failure or emergency. except fbr authorized

and consenting

personnel

that are necessary

for the "purpose",

12. Flight operations

must be conducted

at least 500 fbet from all nonparticipating persons, vessels, vehicles,

andstructures

unless: a) Barriers

or structures

are present

that sufficientlyprotect nonparticipating

persons from the UA and / or debrisin the event of an accident.

The operator

must ensure

that nonparticipating persons remain undersuchprotection. If a situation

arises where nonparticipating persons leave suchprotection

and arewithin 500 feet of the UA, flight operations must cease

immediately and / or; b) The aircraft is operated near vessels, vehicles or structures

where the owner/controller

of such vessels, vehicles or structures

hasgranted

permission

andthe PIC hasmadea safety assessment of the risk of operating closer to those objects and determined

that it does

not present

an undue hazard, and; c) Operations

nearer to the PIC. VO, operator trainees or essential

persons do not present

an undue hazard to those persons per ti 91.119(a). All operations

shall be conducted

over privateor controlled-access property with permission from the properly owner, controller,

or authorized

representative. Permission

from property

owner/ controller

or authorized

representative

will be obtained

for each flight to be conducted. See, Exemptions

11170, 11172 and I 1 17for proposed

language. 13. Prior to any flight "operator"will only be required to obtainanAir Traffic Organization (ATO) issued

Certificate

of Waiveror Authorization (COA) for flights that are conducted at heights greater than 400 AGL; in otherthan Class G airspace;

and closer

than 5 miles fiom the geographic

center of a non-towered

airport,without a letterof agreement with the airport manager.

If requested,

Operator

will provide telephonic advanced

noticeto anATO or file a NOTAM for any flight not requiringa COA. 14.If the UAS loses

communications

or loses its GlobalPositioning

System (GPS) signal, the UA will be programmed to return to a pre-determined

location within the security

perimeter

and land or be recovered

in accordance

with the "manual". l5' The UAS will abort the flight in the event

of unpredicted

obstacles

or emergencies

in accordance

with the'omanual". 

### Date:512112015 Page 6 of 12 

### Revision: Original16. EachUAS operation will be completed

within 30 minutes

flight time or with25V" battery power remaining,

whichever

occurs first.
17. All aircraftoperated

in accordance

with this exemption

will be identifiedby serialnumber, registered

in accordance

with l4 C.F.R.part

47, and have identification (N- Number) markings in accordance

with 14 C.F.R.part 45, subpart C. Markingswill be as largeas practicable.
18. The operator

will institute

procedures

to document

and maintain

a recordof the UAS maintenance,

preventative

maintenance,

modifications,

overhaul

or replacement

of component parts andthe total time in service of the UAS. 19. EachUAS operated under this exemption

will comply with all manufacturer SafetyBulletins.
20. The operator

will develop

UAS technician

qualification

criteria. These criteriawill be added to the Manual. 21. Beforeconducting

operations,

the radio frequency

spectrum

used for operation

and control of the UA will comply with the Federal Communications

Commission

(FCC) or other appropriate government

oversight

agency requirements. 22.The documents

required under 14 C.F.R.

$$ 91.9 and91.203

will be available

to the PIC at the groundcontrol station of the UAS any time the aircraft is operating. These documents

will be madeavailable

to theAdministrator

or any law enforcement official upon request. 23. The UA will remainclear of and yield the right of way to all other manned operations

and activities

at all times (including,but not limited to, ultra light vehicles, parachute

activities, parasailing

activities,

hanggliders,

etc.).
24. UAS operations

will not be conducted

during night, asdefined

in 14 C.F.R.

$ 1.1. All operations

will be conducted

under visual meteorological

conditions

(VMC). Flights under special visual flight rules (SVFR) will not be undertaken. 25. The UAS will not be operated by the PIC from any moving deviceor vehicle. 26.The UA will not be operated less than 500 feet below or less than 2,000 feet horizontally fiom a cloud or when visibility is less than 3 statute

miles from the PIC



### Date:512112015 Page 7 ol 12 Revision: Original

### 27.TheUA will not operate in Class B, C, or D airspace

without written approval fromthe FAA. The UA will not operate within 5 nautical

miles of the geographic center of a non- towered airport as denoted

on a curent FAA-published aeronautical

chart unless

a letterof agreement with that airporl's management is obtained,

and the operation

is conducted

in accordance

with a NOTAM as required

by the operator's

COA. The letterof agreement with the airport management

will be madeavailable to the Administratorupon request.
28. Any incident,

accident,

that occurs

with in the boundaries of the operational

area as defined by the applicable

COA will be reported

to the Federal

Aviation Administration's (FAA) UAS Integration

Office (AFS-80)within 24 hours. Accidents

will be reported

to the National Transportation

Safety Board 0.{TSB) per instructions contained

on the NTSB Web site: www.ntsb.gov.

Further flight operations

will cease

until such

time asthe incident,

accident,

or transgression

is reviewed

by UAS Integration

Office (AFS-80) and authorizationto resume operations

is provided.

Unless otherwise

specified

in this grant of exemption, the UAS, the UAS PIC, andthe UAS operations

must comply with all applicable parts of l4 C.F.R.

including,but not limited to, parts 45. 47.61. and 91.

l4 C.F.R.

g 61.1f3(a)

and (b): Private Pilot Privileges and Limitations: Pilot in Command.

Sections 61

. i I 3(a) and (b) limit private pilots to non-commercial operations.

Because the UAS will not carry a pilot or passengers, the proposed

operations

can achieve

the equivalent level of safety

of current

operations

by requiring

the PIC operating

the aircraft

to havea private pilot's license

rather than a commercial

pilot's license

to operate

this small UAS. Unlike a conventional

aircraftthat carries

the pilot and passengers, the UAS is remotelycontrolled with no living thing on board. The area

of operation

is controlled

and restricted,

and all flights are planned and coordinated

in advance

as setforth in the Manual.The level of safety providedby the requirements includedin the Manual exceeds that providedby a single individual holding a commercial pilot's certificate

operating

a conventional

aircraft. The risks associated

with the operation

of the UAS are so diminished from the level of risk associated with commercial

operations

contemplated

by Part 6l when drafted, that allowing operations of the UAS as requested

with a private pilot asthe PIC exceeds the present

level of safety

achieved

by 14 C.F.R.

$ 61

. 113(a)

and (b). The FAA has granted exemptions

for private pilots to conduct similar operations

in Exemptions

11062. 11063, 11064,11065,

11066, 11067 and 11080.



### Date: 512112015 Page I of 12 Revision: Original14 C.F.R. $ 91.119:

Minimum Safe

Altitudes.

Section 91 .1 19 establishes

safe altitudes for operation

of civil aircraft.

Section 91 .1 19(d) allows helicopters

to be operated

at less thanthe minimums prescribed, provided

the person operating

the helicopter

complies

with any route or altitudes prescribed

for helicopters

by the FAA. As this exemption is for a UAS that is a helicopter andthe exemption

requests authority

to operate at altitudes

up to 400 AGL an exemption may be needed

to allow such

operations.

As set forth herein,

except for the limited conditions stated in the Manual and in condition #3, page 3, the UAS will neveroperate at higherthan 400 AGL.

The equivalent

level of safety

will be achieved

given the size,

weight, speed

of the UAS as well asthe location

where it is operated.

No flight will be taken without the permission of the property owner, facility owner and local officials. Because of the advance

notice to the property owner and participants, all affected

individuals

will be aware

of the planned

flight operations

as setforth in the Manual. Compared to flight operations

with aircraftor rotorcraft weighingfar more thanthe maximum 55 lbs. proposed hereinandthe lack of flammable fuel, any risk associated

with these

operations

is far less

thanthose

presently

presented

with conventional aircraftoperating

at or below 500AGL in the aerialphotography industry.

In addition,

the lowaltitude operations

of the UAS will ensure separation

between these small-UAs operations

and the operations

of conventional

aircraftthat must comply with Section 91.119. The FAA has granted exemptions

to conduct

similar operations

in Exemptions

11062, 11063, 11064, I 1065, 11066, 11067 and 11080.

l4 C.F.R.

$ 91.121:

Altimeter Settings.

This regulation

requires each person operating

an aircraftto maintain

cruisingaltitudeby reference

to an altimeter

that is set "...to the elevation of the departure

airport or an appropriate altimeter

setting available

beforedeparture."

As the UAS in at least one operating

modewill not havea barometric

altimeter,

but instead

a GPSaltitudereadout. an exemption will be needed.

An equivalent

level of safety

will be achieved

by the operator,

pursuant to the Manual and Safety Check list, confirming the altitude of the launchsite shownon the GPSaltitudeindicatorbefore flight. The FAA hasgranted exemptions

to conduct

similar operations

in Exemptions11062, 11063. 11064. 11065. 11066. 11061 and 11080.



### Date:512112015 Page 9 of 12 Revision: Original

### 14

C.F.R. $ 91.151(a):

Fuel Requirements

for Flight

in VFRConditions.

Section 91.151(a)

prohibitsan individual from beginning "a flight in an airplane under VFR conditions

unless (considering

wind and forecast

weather conditions)

thereis enough

fuel to fly to the first point of intended landing, and,assuming

normal cruisingspeed

- (1) During the day, to fly after that for at least 30 minutes;

or (2) At night, to fly after that for at least 45 minutes."

The battery

powering

the UAS provides

approximately

40 minutes

of powered

flight. To meet the 30 minute

reserve requirement

in 14 C.F.R.

$ 91.151,

UAS flights

would be limited

to approximately

10 minutesin length.Given the limitationson the UAS's proposed flight area

and the location

of its proposed

operations

within a predetermined area, a longer time frame for flight in daylight or night VFR conditions is reasonable.
Applicant

believes thatan exemption

from 14 C.F.R.

$ 91.151(a)

fallswithin the scope

of prior exemptions.

See Exemption 10673

(allowing Lockheed

Martin Corporation

to operate without compliance

with FAR 91.151(a)).

Operating

the smallUAS, in a tightly controlled area whereonly people

and propertyowners

or official representatives who have signed

waivers will be allowed,

with less

than 30 minutes

of reserve

fuel, does

not engender

the type of risksthat Section 91.151(a)

was intended

to alleviate

given the size and speed

of the smallUAS. Applicant believes

that an equivalent

level of safety

can be achieved

by limiting flights to 30 minutes

or 25o/o of battery

power whichever

happens first. This restriction

would be more than adequate

to return the UAS to its planned landing zone from anywhere in its limited operating

area. Similar exemptions

have been

granted to other operations,

including Exemptions

2689F, 5745,10673,10808

and Exemptions

11062,11063,

11064,11065,

17066,11067

and11080.



### Date:512112015 Page10 of 12 Revision: Original

### 14

C.F.R. $$ 91.405(a);

407(a)(1);

a09(a)(2\;417(a)

and (b):Maintenance

Inspections.

These regulations

require that an aircraftoperator or owner "shall have

that aircraft inspected

as prescribed

in subpart

E of this part and shall between required inspections,

except as provided in paragraph

(c) ofthis section,

havediscrepancies

repaired as prescribed

in part 43 of this chapter...,"

and others

shall inspect

or maintain

the aircraft in compliance with Part 43. Given that these

section and Part43 apply only to aircraft with an airworthiness

certificate,

these sections will not apply to the applicant. An equivalent

level of safety

will be achieved

because these small UASs arevery limited in size and will carry a small payload

and operate

only in areas for limited periods

of time. If mechanical

issues arise the UAS can land immediately and will be operating

from no higherthan 400 feetAGL. The operator will ensure

that the UAS is in working order prior to initiating flight, perform required maintenance,

and keepa log of any maintenance

performed.

Moreover,

the operator

is the person

most familiar with the aircraftand bestsuited

to maintain

the aircraft in an airworthy condition to providethe equivalent level of safety. The FAA hasgranted

exemptions

for similar operations

in Exemptions11062,11063, 11064. 11065. 11066. 11067 and 11080. Pursuant

o 14 C.F.R.

part 11, the following summary is provided

for publication

in the Federal Register,

shouldit be determined that publication

is needed: Applicant seeks

an exemption

from the following rules:

14 C.F.R. $$61.113(a)

and (b); 91.7(a);9r.r19;9r.121; 91.151(a);91.405(a);9r.407(a) (1);91 .a09@)(2);91.409(a)(2) and91 .al7@) and (b) to operate commercially

a smallunmanned vehicle (55 lbs. or less)in motion picture andtelevision operations.
Approval of exemptions allowing commercial

operations

of UASs for filming and videography

for motion pictureand television work will enhance

safety by greatly reducing

the current risk associated

with conventional

operations

using jet or piston powered

aircraft. These aircraft operate at extremely

low altitudes,

sometimes

only a few feet from the subject being frlmed and in extreme

proximity to people

and structures.

They also present

the risks associated with vehicles

that weigh approximately 4,000 lbs., and carry largeamounts highly combustible fuel. In addition,such

aircraft must fly to and from the project location thereby increasing

the geographic

area of risk. In contrast,

a UAS weighing fewer than 55 lbs. and powered by batteries eliminates

virtually all of the risk associated with conventional

aircraft.Since

the UAS is transported

rather than flown to the locationat which it will be used, it does not require

any crew or contain

passengers,

and therefore

does not expose

individuals

to the risks associated

with manned aircraft flights.



### Date:512112015 Page11 of 12 Revision: Original

### Satisfaction of thecriteria

provided in Section

333 of the Reform

Act of 2012 pertaining

to size, weight, speed,

operating capabilities,proximity to airports and populated areas and operation within visual line of sight and national security provide more than adequate justification for the requested

exemptions

to be granted,

thus allowing commercial operation

of applicant's

UAS for the Purposes

outlined herein and are consistent with exemptions

already granted,including the Similar Exemptions

( I 1 062 through 11067,

I 1 080, 11 I 50,1I I 58 I I I 60,I I 1

6 I and lll72 \.


# t/r, /zo/ { ffi in Marx, President rX The Spot Films



### Date: 512112015 Page12ot 12 Revision: Original